Extension of no-action relief granted in CFTC Staff Letter No. 19-19, which granted relief from prospective compliance with certain position aggregation requirements in Commission Regulation 150.4.

Extension of no-action relief granted in CFTC Letter No. 17-37, which granted relief from compliance with certain position aggregation requirements in Commission Regulation 150.4.

This no-action letter provides relief from compliance with certain position aggregation requirements under Commission Regulation 150.4. 

This no-action letter provides relief from compliance with certain position aggregation requirements under Commission Regulation 150.4.   

The staff letter confirms that, for purposes of applying the position limits set forth in CFTC Regulation 150.2, when an institutional investor qualifies for the Regulation 150.4(b)(1) exemption from position aggregation with respect to their investment in a fund, the institutional investor is not required to look through its investment in a fund to aggregate commodity interest positions of an underlying portfolio company in which the institutional investor may hold a 10 percent or greater indirect interest (via its investment in the fund).  

The Division of Market Oversight provides time-limited no-action relief from certain aggregation requirements under its position limits regime.

Time-Limited No-Action Relief, until 12:01 a.m. eastern standard time on August 14, 2017, from compliance with the notice filing requirements of Commission Regulation 150.4(c), as effective February 14, 2017.

The Division of Market Oversight issued a no-action letter to BNP Paribas confirming that the Division will not recommend that the Commission initiate enforcement action against BNP Paribas or Fortis Bank S.A./N.V., or their respective affiliates, for violation of Commission or exchange speculative position limits, to the extent any such violation results from the application of the Commission’s aggregation policy and rules to the acquisition by BNP Paribas of Fortis Bank.